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Non-Strategic Industrial Premises (amendments to Policy ED2B)

2.94 Placemaking Plan Policy ED2B was adopted in the context of the National Planning Policy Framework 2012. The NPPF 2012 set out a presumption that employment land and premises should be redeveloped for housing, unless there are ‘strong economic reasons’ as to why this would be inappropriate. The revised NPPF published in 2018 continues to encourage the use of previously developed land for housing, and that using currently unallocated retail and employment land for homes should be supported but only where it does not undermine key economic sectors and would be compatible with other policies in the Framework (including those relating to supporting economic growth and productivity).

2.95 Reflecting the latest national policy (NPPF 2019) and the significant losses of industrial land that have occurred since 2011; and the increased demand for industrial accommodation it is proposed that stronger policy protection of non-strategic or other industrial sites should be introduced.

2.96 Current Policy ED2B includes the presumption that applications for residential development of a non-strategic industrial site will be approved, unless strong economic circumstances justifying its retention can be demonstrated. The proposed policy would take a different approach by seeking and presuming retention of non-strategic industrial land for industrial uses, unless it can be demonstrated by the applicant that it is not needed for such uses. This approach would apply to non-strategic industrial sites across the whole District, in order to protect space and jobs across all communities helping to provide local employment opportunities and a fully functioning local economy.

2.97 It is acknowledged that small industrial areas generally accommodate smaller-scale provision and local business needs with local importance for industrial and related functions. The Council will be undertaking research to explore the important role of industrial sites of strong neighbourhood importance. The research will look to analyse the role and importance of these sites to both the local community and the functioning of the local economy in terms of sustainability.

2.98 In applying such a policy approach the Local Plan would need to set out the factors or criteria against which the applicant would need to justify the proposed loss of industrial space and the Local Planning Authority assess whether the site should be redeveloped for other uses.

Consultation Reference DM 27

Amendment to Policy ED2B

1 Proposals for the uses listed in ED2A will be acceptable in-principle at sites already occupied by smaller clusters and stand-alone industrial premises provided that this would not cause unacceptable environmental, residential amenity or highways problems. (no change)

2 Non-strategic sites are not afforded the same level of protection for industrial and warehousing (B1c, B2 & B8 and Egiii) uses as those listed in ED2A. Applications for residential development or others uses will normally be approved unless there is a strong economic reason why this would be inappropriate. However, as the overall stock of industrial premises within Bath and other areas is at a critically low level there is a presumption that sites will be retained for industrial uses unless it can be demonstrated through applying all the criteria below that the site should not be retained for industrial use and development to a new use permitted.

  • Progress against the area specific managed changes in industrial floorspace stated in the Core Strategy
  • Employment & Business Sectoral Growth – growth in business and employment sectors that do or could occupy the site in question
  • Present use - whether the site is presently occupied and the number of people employed on site
  • Suitability/ viability – if the site is not currently occupied whether it is in a condition and location that it can viably continue as an industrial employment site
  • Local significance or role of the site in its industrial use
  • Evidence of unsuccessful marketing on reasonable terms for 12 months prior to an application and during a sustained period of UK economic growth will be taken as evidence that there is not a strong economic reason for refusal.


2.99 Due to the chronic shortage of industrial space within the Bath City area, all existing industrial sites including small sites play an important role to Bath remaining a fully functioning economy. It is also important in ensuring that climate emergency goals are fulfilled - both in terms of employment and last mile delivery. Furthermore, industrial space is required to help facilitate green recovery with evidence of demand for such space shown by inquiries registered with the Council. The ongoing presence of industrial space within the city is essential to a functional employment ecosystem.